Promissory estoppel protects industrial policy incentives: later executive instructions cannot defeat accrued benefits under notified rules.

Governmental industrial policy assurances were held enforceable under promissory estoppel where units had acted on the promise, altered their position, and invested in reliance on notified incentives. The State could not withhold promised subsidies without a legally sufficient basis. Accrued benefits under notified policies and rules could not be curtailed retrospectively by later administrative guidelines or executive instructions; only a lawful prospective amendment could change the regime. The impugned guidelines and orders were set aside, and release of the eligible incentives and subsidies was directed, with interest on default.

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Issues: (i) whether the doctrine of promissory estoppel applied to the State's industrial policy assurances and bound the State to release the promised incentives and subsidies; (ii) whether the State could, by later administrative guidelines or executive instructions, alter the eligibility conditions and deny benefits that had already accrued under the notified policies and rules.

Issue (i): Whether the doctrine of promissory estoppel applied to the State's industrial policy assurances and bound the State to release the promised incentives and subsidies.

Analysis: The industrial policies were notified by the State and were implemented through relevant rules having the force of law. The industrial units acted upon those promises, altered their position, invested substantial sums, obtained finance, and established or expanded units in reliance on the assured incentives. The State admitted the policy framework and the sanction of subsidies, but withheld disbursement on grounds not shown to override the promise. In such circumstances, the governmental assurance was enforceable, and the State could not repudiate it after inducing reliance.

Conclusion: The doctrine of promissory estoppel applied, and the State was bound to honour the promised incentives and subsidies. The finding is in favour of the petitioner.

Issue (ii): Whether the State could, by later administrative guidelines or executive instructions, alter the eligibility conditions and deny benefits that had already accrued under the notified policies and rules.

Analysis: Once the policies were notified and the implementing rules framed, accrued entitlements could not be taken away by subsequent administrative guidelines issued by officers. Such instructions lacked the force to override the policy and rules, could not retrospectively curtail vested benefits, and could not justify denial on grounds such as closure of units or non-availability of funds. Only a lawful amendment could alter the regime, and that too prospectively.

Conclusion: The State could not validly change the eligibility criteria or deny accrued benefits through administrative instructions. The finding is in favour of the petitioner.

Final Conclusion: The writ petitions succeeded, the impugned guidelines and orders were set aside, and the respondents were directed to release the eligible incentives, subsidies, and other benefits within the stipulated time, with interest on default.

Ratio Decidendi: A governmental promise inducing action and altering the promisee's position is enforceable under promissory estoppel, and executive instructions cannot retrospectively defeat benefits that have accrued under notified policy and rules having legal force.

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